Privacy Policy and Modern Slavery Policy

Privacy policy

1. We respect your privacy

(a) Haylo People Pty Ltd respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information.

(b) “Personal information” is information we hold which is identifiable as being about you.

2. Collection of personal information

(a) Haylo People Pty Ltd will, from time to time, receive and store personal information you enter onto our website, provided to us directly or given to us in other forms.

(b) You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

(c) Additionally, we may also collect any other information you provide while interacting with us.

3. How we collect your personal information

(a) Haylo People Pty Ltd collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we provide our services to you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.

4. Use of your personal information

(a) Haylo People Pty Ltd may use personal information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.(b) Haylo People Pty Ltd may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.

5. Disclosure of your personal information

(a) We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.

(b) We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

(c) We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Haylo People Pty Ltd, www.haylopeople.com.au, its customers or third parties.

(d) Information that we collect may from time to time be stored, processed in or
transferred between parties located in countries outside of Australia.

(e) If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

(f) By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

6. Security of your personal information

(a) Haylo People Pty Ltd is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

(b) The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.7.

7. Access to your personal information

(a) You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). A small administrative fee may be payable for the provision of information. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at hello@haylopeople.com.au.

(b) We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.8.

8. Complaints about privacy

(a) If you have any complaints about our privacy practises, please feel free to send in details of your complaints to Suite 7/ Level 1 227 Condamine Street, Manly Vale, New South Wales, 2096. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.9.

9. Changes to Privacy Policy

(a) Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

10. Website

(a) Website – When you come to our website (www.haylopeople.com.au) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

(b) Cookies – We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, thismay prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.

(c) Third party sites – Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Haylo People Pty Ltd is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

Modern Slavery Policy

1. What is the purpose of this policy?

We will limit risks of modern slavery practices in our business and supply chain.

2. Who this policy applies to?

This policy applies to you if you are involved in our business, including if you are an employee, director, officer, labour hire staff, contractor or other representative of our business or of any business in our supply chain.

While this policy is not part of any contract you may have with us, you are expected to comply with it.

If you do not comply with this policy, we may end our business relationship with you and if you are an employee, you may be disciplined or dismissed.

3. What is modern slavery?

Modern slavery is depriving a person of freedom for commercial gain and in violation of fundamental human rights.

It describes situations where offenders use coercion, threats or deception to exploit victims and undermine their freedom. Modern slavery involves serious exploitation, not sub-standard working conditions or the underpayment of workers although this may be unlawful for other reasons.

Modern slavery can take many forms including:

(a) Slavery – owning a person, trading in slaves or financing slave trading (ie, human trafficking)

(b) Forced labour – forcing a person to work by coercion or threats (and servitude is when that person’s freedom is significantly restricted)

(c) Forced marriage – a marriage without free and full consent – eg, due to lack of understanding or duress/coercion

(d) Debt bondage – a person works to pay off a large debt, for an unlimited time or where the value of the work is not applied to the debt

(e) Deceptive recruiting – a recruiter charges a fee for the job offer, confiscates identity documents, deceives a person about personal freedom or their ability to leave the job

(f) Child labour – not always unlawful but not tolerated by us when it involves exploiting children, depriving them of education, making them work in unsafe working environments

Modern slavery can be complex and multi-faceted and can be difficult to spot.

4. What are indicators of modern slavery practices?

Modern slavery indicators may include where a person:

(a) is not in possession of their own passport, ID or travel documents;

(b) is acting as though they are being instructed or coached by someone else;

(c) allows others to speak for them when spoken to directly;

(d) is dropped off and collected from work;

(e) is withdrawn or appears frightened or have physical indicators of slavery, such as injuries;

(f) unable to contact friends or family freely;

(g) has limited social interaction or contact with people outside their immediate environment;

(h) story contains obvious errors;

(i) acts with hostility or have difficulty in concentrating due to trauma;

(j) has few possessions;

(k) has little or no control over their finances or no access to a bank account, or they are being significantly overcharged for their accommodation; and

(l) is living in a very poorly maintained and overcrowded place. These indicators are not exhaustive and do not necessarily mean there are modern slavery practices. Sometimes there may be other reasons or circumstances that indicate that something is not right.

5. Why do we want to limit risks of modern slavery practices?

Limiting modern slavery practices makes good business sense, protecting our workers and our reputation.

It also supports us in assessing and addressing modern slavery risks as required by modern slavery legislation.

6. What are our responsibilities?

We will endeavour to:

(a) identify and address modern slavery risks in our business and supply chain; and

(b) take steps to raise your awareness of modern slavery risks, including by having this policy.

7. What are your responsibilities?

You must take all reasonable steps to ensure our business and supply chain is free of modern slavery practices.

However senior you are and regardless of your business relationship with us, you must pay close attention to the high-risk areas identified in our Modern Slavery Statement, particularly supply chain and outsourcing in jurisdictions without adequate safeguards.

Some areas of the business are likely to have more exposure than others, including procurement and sourcing, human resources, finance, risk, sustainability, projects, legal and leadership.

Examples of specific responsibilities include:

(a) participating in all training, including in this policy;

(b) leading by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc to ensure we know who is working for us;

(c) remaining alert to indicators of slavery (see above);

(d) using only approved contracts which include modern slavery clauses; and

(e) obeying our instructions regarding modern slavery.

Turning a blind eye is unacceptable and if you reasonably suspect there may be modern slavery, report it under this policy.

8. How do I report slavery concerns?

If you have a reasonably held suspicion of modern slavery practices, discuss your concerns with ( ), who will decide a course of action and provide any further advice.

If there is immediate danger call the police — don’t tackle a situation on your own as dangerous criminals can be behind modern slavery and human trafficking.

Not all victims may want to be helped and sometimes, reporting a suspected trafficking case puts the potential victim at risk, so it is important that unless there is immediate danger, you discuss your concerns first with before taking any further action.

Keep your eyes and ears open—your awareness and actions may stop someone from being exploited or abused.

9. Who is responsible for this policy?

Our board of directors are responsible for this policy and will review reports of material slavery concerns.